Electrical and Electronic Equipment and the Environment Conference 2017
by Michelle Carvell at 23:56 in Content, Circular Economy, Environmental, Origin, Emerging
Lorax Compliance Ltd visited the RINA Consulting conference on Electrical and Electronic Equipment and the Environment 2017 at the Heathrow Hilton on 1st/2nd November and enjoyed 2 days of fantastic learning and networking. In an agenda packed full of updates on legislation, analysis of studies and presentations from companies handling electronics, it is hard to pick only one focus of interest, however a number of key themes wove themselves across the two days.
New Legislation
Environmental legislation has a habit of not standing still and both new and existing legislation topics were covered. Updates about both RoHS in China (China RoHS 2) and Eurasia showed differences when comparing to the EU version of the legislation. There are variances within both the category scope and labelling requirements. Whilst EU RoHS has been around for many years and isn't changing (just yet), many industries heavily rely on the exemptions. These are not static, and whilst they can be added to, they also expire and must be re-applied for if companies want to keep using them. This isn't a quick process and companies should look ahead at least 18 months to ensure they have time to complete the paperwork involved!
Switching the attention to REACH, we were also reminded to expect inevitable changes after the 2018 REACH deadline for registration next year. 140,000 substances were pre-registered and to date less than 20,000 of them have been converted to full registrations, which shows there could be a lot of work still to do for some businesses.
EcoDesign legislation also hit the agenda and we were provided a reality check that most TV's on the market would be removed under current standards!
Non-Compliance
A key message coming through several of the presentations was concern over the level of compliance. This ranged from a number of demonstrated instances of non-compliance to concern over the level of detail and engagement companies are placing on material and supply chain assessments. Through a series of presentations covering the effectiveness of the Modern Slavery Act, OECD guidance reviews for Conflict Minerals policies, Responsible Recruiting and product energy enforcement, data and analysis showed that there is still much to be done, especially to take compliance from just a tick-box exercise to engagement at every level of the process. Within one analysis of UK Modern Slavery statements, only 18% were found to be compliant. Many more statements which were expected are missing completely.
In contrast to these results we also heard two talks which discussed the enforcement of legislation. For REACH, enforcement has always been a Member State responsibility, however countries have often carried this out differently due to different interpretations of the Article. Now that the Article 33 changes have clarified the definition of an Article, we should expect to see REACH enforcement high on the agenda. A ECHA pilot project has just started which will provide training for national coordinators and determine which substances will be inspected. KEMI (the Swedish chemicals agency) also talked us through their enforcement process. Testing is extensive, and the discussion reinforced the message that there are still many instances of non-compliance, in both labelling and through the presence of restricted substances.
Supply Chain
The topic of supply chain management surfaced across a range of talks, from materials management to a thought-provoking discussion about recruitment fees often forced on migrant workers, however, the key message was transparency. Whether it was for sustainability statements, discussing who should hold responsibility beyond Tier 1 suppliers or highlighting that materials management shouldn't stop at 3TG, the feeling seemed to be aligned around knowing more, not less.
Brexit
No discussion on regulation can be complete at the moment without including questions around Brexit. Raised several times, and usually causing lively debate, Brexit is an issue of concern that may not be completely resolved by the March 2019 deadline. Talks from both the IEEP and DEFRA reinforced the complexity ahead with negotiation and practical untangling when decisions are finally made. The UK has, on the whole, been a strong supporter of EU environmental legislation and whilst a lot will pass automatically into UK law, decisions around REACH amongst others are still in progress. Whilst no decision has been made on the usage or replacement of ECHA in UK chemicals management, it is clear that having to set up a UK chemicals agency would be a challenging task. We should also note that many environmental policies in the UK are devolved, so we could see the governments of Wales, Scotland and NI taking policy in different directions in the future.
Despite the Brexit progress gloom and doom, an interesting discussion was had about whether anything will really change after we leave. There is already so much documentation in place when exporting from the UK into the EU, that we can't really call the existing border frictionless! A potential option for the future is to align our export process into the EU with the Customs Entry process in place for exporting outside the EU, making one system worldwide, would save time for everyone.
Get in touch if you would like to share your thoughts on any of the topics above. Thank you to all the speakers and organisers for making the event informative, interesting and fun. We'll see you next year!
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